(Published as Crowdfunding Q&A 3.9)

No. The reference made in point (ii) of point (c) of Article 1(2) of the ECSPR is strictly meant to capture the total consideration of offers of securities made by the project owner in its capacity as offeror pursuant to the exemption under Articles 1(3) and, when applicable, the exemption under 3(2) of the Prospectus Regulation. Consequently, the consideration of offers referred to in point (a) and (b) of Article 1(4) of the Prospectus Regulation made by the project owner in its capacity as offeror should not be taken in consideration for the purpose of the calculation of the threshold referred to in point (c) of Article 1(2) of the ECSPR.